We will certainly not experience regulatory calm. The omnibus bill concerning CSRD and CSDDD is behind us, but in November the Commission launched the process of changes to the SFDR regulation, and in December presented environmental omnibus bill. They are somewhat less talked about among those involved in sustainable development, although they may bring about more significant changes. After all, the SFDR shapes companies' access to sustainable financing, and the second package of changes concerns, among other things, the Industrial Emissions Directive and extended producer responsibility. We still have ahead of us a revision of the EUDR regulation and two initiatives that I consider to be the most significant: the inclusion of sustainability criteria in public procurement and the amendment of regulations on the circular economy.
It is also certain that EFRAG will provide us with a lot of interesting materials that will facilitate the application of simplified ESRS standards. We will have to adapt the implementation guidelines, update the documents presenting the interoperability of ESRS with IFRS and GRI standards, develop new guidelines on the methodology for calculating the expected financial effects (if you don't know how to calculate them, don't worry, everything will be clearly presented), and further develop the new ESRS Knowledge Hub and the VSME ecosystem. EFRAG's work program for 2026, which we recently discussed at a joint meeting of the SR TEG and SR Board, looks not like an annual plan, but at least a five-year plan 😉
We will continue to see very dynamic growth in the installation of new renewable energy generation capacity, and I expect that once again more than half of this growth worldwide will be generated by China. For two years now, the increase in energy consumption in China has been covered exclusively by new solar and wind power capacity, while fossil fuel consumption is stagnating. With each passing month, it will become easier to make a commercially viable decision to decarbonize by electrifying another element of a company's operations, mainly due to the steadily declining costs of photovoltaic installations and energy storage. Will companies easily obtain attractive financing for such projects? This may be more difficult, as one of the effects of the first Omnibus will be to concentrate the availability of sustainable financing exclusively for the largest corporations – although this may not be visible in 2026, but in subsequent years. Unfortunately, it will be more difficult for „smaller among large” companies and medium-sized enterprises.
I am very curious to see how companies that were supposed to be covered by the CSRD directive but ultimately avoided this obligation will approach reporting. Some of them will breathe a sigh of relief. Others, for various reasons, will decide that voluntary reporting makes sense. This is especially true when it is the end result of ongoing activities, presenting data, information, and achievements in sustainable transformation to business partners, financial institutions, and customers. Which companies will choose the simplified ESRS standards (in my opinion, the best choice for large enterprises), which will opt for IFRS or GRI standards, and which will try to create meaningful reports using the VSME guidelines?
However, what interests me most is how Polish and European companies will begin to adapt to the requirements set by business partners outside Europe in terms of sustainable development. IFRS standards are already in force or are being implemented in more than thirty countries. Several dozen countries around the world are implementing taxonomy systems, modeled to a greater or lesser extent on our European one. Some countries, including those in Southeast Asia, are preparing mandatory due diligence regulations. Will we see the first effects in 2026 or only in subsequent years? What data and information will our business partners from these countries expect from us? Will it be easier for us to implement due diligence processes if the entities in our value chain clearly express their expectations in this regard?
I am convinced that 2026 will be marked by even more dynamic changes than the ending 2025. It is worth equipping ourselves with an interdisciplinary approach and systems thinking 😊
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